“Ryanair must change”. This simple message, emblazoned on T-shirts in the familiar shades of yellow and blue, stood out loud and clear in airport lobbies of at least seven countries on 28 September. Workers gathered as early as 5.30 a.m. around placards and coffee thermoses to denounce Ryanair’s “low fares made simple” business model, in an unprecedented transnational strike which involved thousands of employees and resulted in 250 cancelled flights across Europe.

Ryanair workers share a common diagnosis of their situation: their conditions are unfair and the top management in Ireland is to blame. It signs employment contracts under Irish labour law with its crews based in countries such as Belgium, Germany, Portugal and Spain. This way, many employees cannot benefit from the (more protective) working conditions guaranteed under the laws of their own countries.

This isn’t a rule that Ryanair applies uniformly, though. Conveniently, the company has no problem in applying Polish law to their employees in Poland, as cabin crew staff can be legally hired there as self-employed workers, thus losing their union rights. Apparently, some national labour laws seem sufficiently attractive for Ryanair to apply them, but not others.

Grassroots collective action flourishes in a hostile environment

Establishing a trade union presence, let alone organising a strike, has not been easy in Ryanair. The company is well known for its openly anti-union posture and intimidation tactics. Ryanair workplaces have therefore remained out of reach for traditional trade unions for a long time. In the end, though, fed-up workers used a very traditional method to voice their discontent: a strike.

Technically, most workers could not declare themselves on strike, having to use up one of their days off to avoid reprisals from management. However, it is deeply significant that, despite 30 years of threats from management, Ryanair’s crew were able to collectively organise, and transnationally at that. A strike in the low-cost airline not only has serious repercussions for the company but also an impact on third parties, i.e. passengers. Remarkably, however, passengers in Belgium (even those with cancelled flights) supported the striking workforce. There are elements of this strike that recall the radical energy of the early labour movement, before it became institutionalised.

How did the Ryanair workers develop transnational solidarity?

Collective action can unite workers across corporations and national boundaries. The Ryanair strike was a good example. The company’s workforces in Belgium, Spain or Ireland are not Belgian, Spanish or Irish but of many nationalities. This transnational work community shares not only similar precarious working conditions but also work and living spaces close to the airport, creating connections. Over the years, despite setbacks, a strong organisational capacity has developed across borders.

Of course, workers’ short-term strategies may diverge depending on their context. It would be difficult for employees in Ireland to claim that Irish law is legally inappropriate; those in Poland, meanwhile, won’t gain much by fighting for the application of their weaker national labour standards. These groups of workers may find it more practical to negotiate for improved conditions or even for maintaining their contracts under Irish law.

Furthermore, some Ryanair bases couldn’t even join in the action, simply due to a lack of trade union representatives. Nevertheless, workers succeeded overall in coordinating transnationally by stressing the international character of the workforce, their problems and their demands. This framing of the issues also amplified the impact of the action across Europe.

We can take home several lessons from the Ryanair cabin crew and pilots’ action. First, workers can still organise effectively and challenge the ‘new’ economy from below, as has also been shown in the recent Deliveroo and McDonald’s strikes. Second, while these workers may not be the ‘typical’ trade unionists, being young and often new to union activism, their direct experience of daily injustices at work makes them well equipped to fight together for fairer conditions in the ‘Industry 4.0’ era. Finally, when issues are transnational, transnational action makes sense. Only one piece is missing in the jigsaw: transnational solutions.

European-level solutions needed

In their call for solidarity, Ryanair workers mobilised a range of power resources and tools. They kept each other informed via social media, recruited new members, attracted press attention, and found allies and supporters in local and international trade union federations, left political parties, the wider public, national authorities and even the European Commission. The European Court of Justice also got involved recently, ruling that disputes between Ryanair and its crew can fall under the jurisdiction where the worker is based, a decision that transport unions considered a significant setback for Ryanair.

While seeing workers fight injustice through transnational action is inspiring, it also exposes how Europe is not delivering on the social dimension. Clearly, the EU common market can be abused by unscrupulous employers aiming to circumvent workers’ rights. Some trade unions are demanding European harmonised solutions to address this issue. After all, workers’ common and long-term objective is to achieve better working conditions and improved social protection, wherever they are. It is time for the cross-country solidarity shown at the grassroots level to be reflected at the level of EU policy.

The diversity of national labour rules has unequal consequences for multinationals and workers in the EU common market. While companies freely operate across borders and can pick and choose national jurisdictions to their own advantage, workers are much more constrained. Only a legislative harmonisation of social standards could make upward social convergence conceivable in Europe and prevent social dumping and legal regime shopping at the expense of workers.

The issue at stake is not the primacy of ‘national’ labour law but rather an examination of the quality and content of labour rights in every country. And the battlefield where this struggle will play out is Europe.

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